1
Attachment
6
Nonattainment
Area
Designations
for
Athens
under
the
PM2.5
Standard
Additional
Analysis
for
Oconee
and
Madison
This
document
contains
Georgia
EPD's
analysis
of
Oconee
County
for
possible
inclusion
in
the
Athens
PM2.5
nonattainment
area.
EPD
has
already
analyzed
Clarke,
Madison,
Walton,
and
Jackson
County
in
EPD's
June
17,
2004,
submittal
to
EPA.
The
analysis
for
Oconee
County
is
conducted
in
a
similar
manner
as
these
other
Athens
area
counties.
On
June
29,
2004,
EPA
submitted
a
letter
to
Governor
Perdue
indicating
EPA's
intention
to
modify
Georgia's
recommended
PM2.5
boundaries
including
the
Athens
nonattainment
area.
EPA's
June
29,
2004,
letter
stated
that
Madison
and
Oconee
counties
should
be
included
in
the
Athens
PM2.5
nonattainment
area.
Since
EPD
has
already
analyzed
Madison
County,
this
analysis
focuses
on
Oconee
county.
This
document
also
analyzes
meterological
factors
for
Madison
County
since
such
analysis
was
not
conducted
as
part
of
EPD's
June
17
submittal.

EMISSIONS
AND
AIR
QUALITY
ANALYSIS
EPD's
Updated
L­
Score
analysis
(
see
Table
6
of
EPD's
June
17,
2004,
submittal)
resulted
in
an
L­
Score
of
5.85
for
Oconee
County,
the
8th
highest
for
the
15
counties
analyzed
by
EPD.
U.
S.
EPA's
Weighted
Emissions
Score
for
Oconee
County
is
30.5,
the
7th
highest
of
15
counties
analyzed.
These
datum
indicate
that
the
urban
excess
emissions
from
Oconee
County
do
not
contribute
significantly
to
PM2.5
levels
in
Athens
compared
to
other
area
counties.

ANALYSIS
USING
OTHER
FACTORS
EPD
has
analyzedOconee
County
using
the
seven
other
factors
as
described
in
U.
S.
EPA's
April
1,
2003,
memorandum
"
Designations
for
the
Fine
Particle
National
Ambient
Standards":

1.
population
density
and
degree
of
urbanization
2.
traffic
and
commuting
patterns
3.
expected
growth
4.
meteorology
5.
geography/
topography
6.
jurisdictional
boundaries
7.
level
of
control
of
emissions
Page
6
of
the
April
1,
2003,
EPA
memorandum,
states
that
8­
hour
ozone
nonattainment
boundaries
should
be
considered
in
when
recommending
nonattainment
boundaries
for
PM2.5.
The
Athens
area
was
designated
as
attainment
under
the
8­
hr
ozone
standard.

The
following
thresholds
were
used
to
determine
whether
or
not
a
county
met
criteria
1,
2,
or
3.

A.
Population
Density
 
139
persons
per
square
mile
[
Derived
from
the
lowest
projected
2002
population
density
of
any
county
with
a
monitored
violation]
B.
Percent
Population
growth
­
20%
(
minimum
percent
urbanization
considered
by
the
U.
S.
Census)
and
2713
persons
[
Derived
from
lowest
increase
in
population
of
any
county
with
a
monitored
violation]
for
the
period
1990­
2000.
(
To
meet
this
criteria,
a
county
would
have
to
meet
or
exceed
both
the
percent
growth
and
numerical
growth
thresholds.
This
takes
into
account
the
fact
that
a
county
with
a
low
population
can
experience
a
high
percentage
growth
rate
with
only
a
small
increase
in
actual
population.)
2
C.
Percent
Urbanization
 
35%
(
minimum
percent
urbanization
considered
by
U.
S.
Census
Bureau)
for
2000
D.
In
Commutes
 
At
least
8913
vehicles
commuting
into
a
core
county
or
a
county
with
a
monitored
violation.
The
in­
commute
into
core
counties
or
counties
with
a
monitored
violation
was
only
considered
for
those
counties
outside
a
current
non­
attainment
area
[
Derived
from
15%
(
minimum
commute
considered
by
U.
S.
Census
Bureau
in
MSA
determinations)
multiplied
by
59,418
vehicles]
E.
Vehicle
Registration
 
59,418
vehicles
[
Derived
from
the
lowest
2003
vehicle
registration
of
any
county
currently
with
a
monitored
violation].
F.
Vehicular
Miles
Traveled
(
VMT)
in
county
 
742,000
miles
[
derived
from
lowest
2002
VMT
of
any
county
currently
with
a
monitored
violation]

The
specific
values
for
each
of
these
criteria
for
the
counties
analyzed
are
shown
below
and
are
compared
to
the
threshold
values.

Meteorology,
geography,
topography,
jurisdictional
boundaries,
and
level
of
control
of
emissions
are
considered
on
a
qualitative
basis
for
each
county.

Population
Density
 
County
Population
Density
persons/
square
mile
Oconee
147
Threshold
139
Oconee
County
exceeds
the
threshold
for
population
density
only
slightly.

Population
Growth
­

Population
Growth
County
percent
persons
Oconee
49%
8607
Threshold
20%
2713
Oconee
County
both
the
percent
and
total
persons
thresholds
for
population
density.

Percent
Urbanization
­

County
%
Urbanization
Oconee
49.7%
Threshold
35%

Oconee
County
meets
the
threshold
for
percent
urbanization.

In
Commutes
­

County
In­
Commutes
to
Clarke
Co.
3
Oconee
6696
Threshold
8913
Oconee
County
does
not
meet
the
threshold
for
commuting
to
Clarke
County.

Vehicle
Registration
 
County
vehicle
registration
Oconee
29,863
Threshold
59,418
Oconee
County
does
not
meet
the
threshold
for
vehicle
registration.

Vehicle
Miles
Traveled
 
County
VMT
Oconee
1,304,968
Threshold
1,557,806
Oconee
County
does
not
meet
the
threshold
for
vehicle
miles
traveled.

Summary
of
Quantitative
Factors
 
Oconee
County
meets
three
of
the
six
quantitative
criteria,
but
one
of
them
(
population
density)
only
slightly.

Meteorology
 
Wind
frequency
data
was
obtained
from
U.
S.
EPA's
PM2.5
Designation
Technical
Information
web
page
(
www.
epa.
gov/
ttn/
naaqs/
pm/
pm25_
tech_
info.
html)
for
Clarke
County
(
the
county
where
the
violating
monitor
is
located).
The
data
show
a
strong
indication
of
prevailing
winds
from
the
west.
Oconee
County
is
located
to
the
south
of
Clarke
County.
Madison
County
is
located
northeast
of
Clarke
County.

Geography
­
Oconee
County
is
adjacent
to
the
county
(
Clarke)
that
has
a
violating
monitor.
There
are
no
other
geographical
factors
affecting
these
counties.

Topography
 
There
are
no
topographical
issues
that
affect
air
quality
in
the
Athens
area.

Jurisdictional
 
Oconee
County
is
part
of
the
Athens
Metropolitan
Statistical
Area
(
MSA).
Oconee
County,
as
well
as
the
rest
of
the
Athens
area
is
under
the
jurisdiction
of
Georgia
EPD.

Level
of
Control
of
Emissions
 
Oconee
County
is
subject
to
the
following
six
air
quality
control
measures
that
are
more
stringent
than
elsewhere
in
the
state:

391­
3­
1­.
02(
2)(
lll)
­
NOx
Emissions
from
Fuel­
burning
Equipment
391­
3­
1­.
02(
2)(
mmm)
­
NOx
Emissions
from
Stationary
Gas
Turbines
and
Stationary
Engines
used
to
Generate
Electricity
391­
3­
1­.
02(
2)(
nnn)
­
NOx
Emissions
from
Large
Stationary
Gas
Turbines
391­
3­
1­.
02(
2)(
bbb)
­
Gasoline
Marketing
391­
3­
1­.
02(
5)(
b)
2
 
Open
Burning,
Specific
County
Restrictions
4
CONCLUSION
Based
on
the
above
factors
and
the
revised
L­
Scores
analysis
conducted
by
EPD,
we
conclude
that
Oconee
County
should
not
be
included
in
the
Athens
PM2.5
nonattainment
area.
This
analysis
also
shows
that
meterological
factors
do
not
indicate
that
Madison
County
should
be
included
in
the
Athens
PM2.5
nonattainment
area.
